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Supreme Court of India 2022-05-18 allowed

Rajpal Singh vs Saroj (Deceased) Through LRs and Anr

Bench: 2 — M.R. Shah, B.V. Nagarathna

In Brief

The appellant purchased agricultural land on the basis of an agreement to sell dated 1993. The seller's wife obtained a collusive decree in a separate suit in 1995 claiming the land as her share in a family settlement, without notifying the appellant. The seller then executed a registered sale deed in the appellant's favour in 1996 and received full payment. The seller's wife filed a suit to cancel the sale deed over five years later. The Trial Court cancelled the deed based on the earlier decree. The First Appellate Court reversed this, finding the suit barred by limitation (three years from the registered deed, not twelve) and the earlier decree collusive. The High Court restored the cancellation. The Supreme Court held the suit was barred by limitation as the substantive relief (cancellation) must be assessed within three years from the deed's registration in revenue records, not by the twelve-year period for the consequential relief (possession). Appeal allowed.

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Limitation Law Property Law Sale Deed Cancellation Specific Performance Fraud Collusive Decree Bona Fide Purchaser Mutation of Revenue Records

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